Playing “Who’s on first, What’s on second, I Don’t Know is on third” – with EPA’s R-134a refrigerant replacement (HFO-1234yf)

I may have been quick to “pat myself on my back” last week with my post titled “It took two (2) years, but HFO-1234yf is now a NFPA Flammable “4”, as this morning I learned from another client dealing with this refrigerant that their manufacturer also updated their SDS and guess what… that manufacturer went from an NFPA Flammable “4” down to a Flammable “2”.  So hence my title of this post..Who’s on first, What’s on second, I Don’t Know is on third – with EPA’s R-134a refrigerant replacement.  The rollout of this new refrigerant has been nothing short of a complete cluster _______ and it is occurring in an industry (e.g., automobile manufacturing) that is new to OSHA’s process safety standard.  So here is where we stand today (there are no guarantees for next week!)…

As a stated last week, one of the two manufacturer’s of HFO-1234yf (2,3,3,3-Tetrafluoropropene with a CAS# of 754-12-1) revised its NFPA 704 Labeling criteria to a NFPA Flammability of “4” and Health of “3”, which was quite a jump from what some automobile manufacturers were told in the early days of it being a NFPA Flammability of “1” and Health of “1”.  I was quick to take a sigh of relief as I felt vindicated last week after being called everything a professional safety hopes never to be called after telling several facilities that this Category 1 Flammable Gas was indeed a NFPA “4” and there was just no getting around it.  

And yet, as confident I was in my position, today I find out that the other manufacturer of this refrigerant ALSO REVISED their SDS in September 2017 and their revision put the Chemical at a Flammability of “2” and a Health of “2”; which was a significant change from where they were earlier with a Flammability of “4”.

Here are the SDS:

* Manufacturer B never had an SDS that I am aware of that provided NFPA labeling guidance, but I have been privileged in some client communications where they made claims of a lesser rating.  PLEASE see my post from last week showing a storage tank labeled 1-1-1.  

FYI, if you needed more data to confuse you a bit more, we have another SDS from a “supplier” that has this material rated as a 4-1-0

I want to be clear here, ALL of these SDSs and all the other ones I have read and that are not listed above have one (1) critical piece of data in common; they ALL have this refrigerant listed as a CATEGORY 1 FLAMMABLE GAS.  And as I stated back in my August 2015 post, Refrigerant HFO-1234yf is a PSM Highly Hazardous Chemical (Part 1), this “qualifies” this material as a PSM Highly Hazardous Chemical and a process which contains over 10,000 pounds of this refrigerant is indeed – WITHOUT QUESTION – a PSM Covered Process. 

So why all the fuss with SDS revisions?

Clients who are in the process of implementing their safety programs (including PSM) have been at odds on which labeling data to use.  One client is about 90% through their PSM implementation (which includes HAZCOM implementation), only to now go back an revise their vessel labeling for the third time, as well as update the following:

1. Their process battery limits signage (these signs happen to have the old NFPA ratings)
2. Their HAZCOM training materials (the presentation had the older NFPA ratings)
3. Their Contractor Safety Training materials (the materials had the older NFPA ratings)

This is all based on having gone from a NFPA 2-1-0 to a 4-2-1, and now having a 2017 SDS that calls for an evaluation of 4-3-0.  Of course, they could swap to the other manufacturer’s 2017 SDS and go with the 2-2-0.  Of course, even then, they would still have to revise all their signs and programs as that would be yet another NEW set of NFPA labeling data for them on this refrigerant.

So how does a chemical that was introduced to the industry in 2007 get so many revisions in 10 years?

Folks this may be the $64,000,000 question! If we think back over the years of managing our MSDSs, many never got revised, and I for one can not think of any chemical I have worked around that got this many revisions – much less to this degree (i.e., a NFPA 1-1-0 to a 4-3-0).  And for two major players in the chemical industry to not be able to agree and align on how to label this chemical using either NFPA 704 or HMIS is just unheard of.  Sure, we all had to revise our old MSDSs to meet the new GHS SDS format, but these NFPA Labeling revisions are NOT about the new “SDS format” (although the GHS category system may be causing some of this confusion).  But I can say for a fact that the chemical properties and NFPA 704 have not changed.  So why so much confusion????

Imagine if your facility invested millions of dollars in a new chemical to replace a chemical and I told you this new chemical was a 1-1-1 and would lessen your risks.  Only to come back and tell you that actually, the chemical should be a NFPA 4-3-0 and it requires your facility to become a PSM facility. 

If this were only a bad dream… unfortunately it is happening in 2017! Shameful is a term that comes to mind.